6 Common Pharmaceutical Waste Disposal Program Mistakes
There is a lot to consider when it comes to the proper disposal of DEA waste, from evolving regulations to stringent and required procedures. Because of the complexity, it can be easy to inadvertently overlook a few areas. Come audit time, failure to address these compliance issues could result in some hefty fines. Here are six common pharmaceutical waste disposal program mistakes you should avoid to prevent non-compliance.
1. Not involving key stakeholders during the pre-rollout process
Set up meetings with key stakeholders including environmental health and safety (EHS), pharmacy, nursing, and EVS departments. These initial meetings should confirm the plan for key focus areas of the program, such as waste characterization, segregation, training, and disposal procedures.
2. Cutting corners during the informational phase
Be sure to obtain a formulary to properly characterize waste and include hidden waste streams not listed on the formulary. Additionally, determine if there are any federally-listed exemptions (e.g., epinephrine, residues, phentermine salts). Meet with departments (radiology, wound care, materials management) to determine what items are being purchased for individual department operations. Accurate formulary and waste characterization will disclose:
- Which medications are considered hazardous DEA controlled substances under federal regulations
- Which medications are incompatible and need to be separated from other medications
- What sizes and types of containers are required
- What kinds of labels/signage should be used on the containers
3. Not involving the appropriate team members during the operational phaseMeet with the involved departments to set the go-live date, to identify satellite accumulation areas (SAAs), and to determine waste collection and training methods whether conducted by an internal staff or outside vendor.
4. Not properly training staffEnsure proper initial and ongoing training for pharmacy, EHS, nursing, and laboratory staff as well as new hires. Trainings should be department-specific according to the duties of the employees in each department and their involvement in hazardous waste management. Employees must be thoroughly informed and up-to-date on what types of pharmaceutical waste your facility produces, where it is stored, and how it is transported and disposed of. They should also be aware of which pharmaceutical waste containers to use for different waste types or medications.
5. Not incorporating off-site locationsConnect with a main contact at any off-site locations to determine what pharmaceutical and hazardous waste they are generating and how it is being managed. Having a streamlined program across all locations allows for uniform training, signage/labeling, and disposal method.
6. Not monitoring post-rollout activities
Perform an annual evaluation of your pharmaceutical waste disposal program to determine how it is operating. Additionally, perform routine SAA inspections.
At Triumvirate Environmental, we take pride in being a dependable, safe, and trusted partner to our customers. As a DEA-Approved Reverse Distributor, we can provide comprehensive management and disposal of your company's DEA controlled substances. Learn more below.